“The goals of the BSA of generating actionable information regarding significant illicit activity that meets the priorities and threshold loss levels that match modern day crime and CT challenges are an unfulfilled vision, not a current reality.”
In his new white paper The Time is Now to Overhaul the Bank Secrecy Act (BSA): The BSA Should Facilitate the Generation of Actionable Information and Interbank Collaboration Chris Swecker, former Assistant Director of the FBI makes a compelling argument that “Initiating or significantly enhancing a full investigation based on a SAR filing was, and still is, the pinnacle of the SAR program.”
Swecker opines that to fulfill the most important purpose of the BSA, a redesigned SAR system must be at the top of the list. He discusses several recommendations to facilitate the research and production of significant SARs and states that “FIs must be incentivized and even credited when they collaborate to generate “super SARs” that federal agencies can use to initiate and significantly enhance priority investigations.”